2026-VIL-49-AAR
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SGST Advance Ruling Authority

GST – Gujarat AAR – Rendering of consultancy services and project management consultancy services to Local Authority - Applicant, a firm of architects, was providing consultancy services and project management consultancy services for the proposed construction of a fire station, staff quarters, and a multi-level parking complex for the Ahmedabad Municipal Corporation (AMC) - Whether the consultancy services provided by the applicant for the construction of the fire station, staff quarters, and multi-level parking complex are exempt from GST under Entry No. 3 of Notification No. 12/2017-Central Tax (Rate) – HELD - The services provided are primarily preparation of architectural and structural drawings, consultancy services, preparing estimates, drawing up detailed tender documents, furnish completion plan of the buildings, checking measurements of work at site and final certification of bills for electrical, civil and other works. It is clear that no element of supply of any goods is present in the scope of services to be provided by the applicant to the AMC nor is it a works contract service as no transfer of property in goods is involved. Hence, the services provided by the applicant fall under the ambit of ‘Pure Services’ - The services were provided to a local authority, the AMC, which falls within the definition of a "local authority" under the CGST Act. The functions of providing fire services and public amenities such as parking lots are entrusted to a municipality under Article 243W of the Constitution. The construction of the fire station and multi-level parking complex fall within these functions - Since the staff quarters were located within the premises of the fire station and were essential for the functioning of the fire services, they are part of the fire services function - Since all the conditions stipulated in Sl. No. 3 of Notification No. 12/2017-CT (Rate) dtd. 28.06.2017, as amended, stands fulfilled in respect of the service in question supplied by the applicant to the AMC, the applicant is eligible for the exemption from GST – Ordered accordingly
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